FACILITY AUDIT FORM. FACILITY CAPABILITIES AND CAPABILITIES SCHEDULES (Check Attached Schedules)

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1 FACILITY AUDIT FORM I. CORPORATE DATA II. SITE DATA A. General Site Data B. Site Financial/Insurance Factors C. Site Environmental Factors D. Site Management Factors E. Site Permits and Regulatory Factors III. GENERAL FACILITY STANDARDS A. Security B. Safety C. Emergency Response D. Laboratory E. Environmental Monitoring F. Transportation G. Waste Receipt and Shipping H. Waste Acceptance IV. FACILITY CAPABILITIES AND CAPABILITIES SCHEDULES (Check Attached Schedules) X A. Container Storage X B. Tanks C. Waste piles D. Surface Impoundments E. Solvent Recovery F. Carbon Regeneration G. Resource Recovery X H. Incineration (prep.) I. Special Waste Physical/Chemical/Biological Treatment X J. Facility Wastewater Treatment K. Landfarm L. Sanitary Landfill M. Secure Chemical Landfill N. Deep Well Injection X O. Solidification/Fixation

2 I. CORPORATE DATA Company Name and Mailing Address: VEXOR Technology Inc. 955 West Smith Rd. Medina, OH Phone Number: Local: (330) Fax: (330) EPA ID #: OHD Facility Rep: Pat Oberth, Corporate Facility Manager (330) Parent Company: VEXOR Technology, Inc. Year Company was established: June, 1999 Owner of Land: VEXOR Technology, Inc. Previous Owner of Facility: Nasco Use: Solvent Chemical Packaging Original Facility: Hood Chemical Use: Chemical Mixing /Blending Original Owner Started Facility in: 1961 Other Similar Facilities (with locations) Owned/Operated by Current Owner: None

3 Is waste management the Company s principal business?: Yes If not, describe the Company s principal business (e.g. chemical manufacturing, formulating, distribution, etc.) Estimated percent of interstate business: 50% Estimated percent of intrastate business: 50%

4 II. SITE DATA A. GENERAL SITE DATA Site Address and Location: (Give detail on approach trucks would take to site) 955 West Smith Rd. Medina, OH Principal Contact at Site: Pat Oberth, Corporate Facilities Manager, (330) Total Size of Site: 5.3 Acres Total Area Used: 1.5 Acres Sq. ft. enclosed total in use at present time: sq. ft. Do operations in additions to waste treatment/disposal take place at the site? No B. FINANCIAL/INSURANCE FACTORS Does the site have worker s compensation? Yes Carrier: Ohio BWC Does the site have general liability insurance? Yes Carrier: Zurich American Insurance Company of Illinois Does the site have umbrella policy coverage? Yes Does the site have a funding instrument to cover the amount necessary to cover the amount necessary to close the facility? No Does the site have a funding instrument for post closure? No

5 II. SITE DATA (continued) C. ENVIRONMENTAL FACTORS Nearest neighbors to the site. Residential: One mile Agricultural: One half mile Commercial: One half mile Industrial: One quarter mile Do neighbors use wells for: Drinking water supply? No Industrial water supply? No Use municipal water? No Nearest water resource and its use (select closest stream, river and/or lake: give distance in miles): Nearest water resource used for drinking water (distance in miles): Lake Erie- 30 miles D. SITE MANAGEMENT FACTORS 1. Site Employees 33 Total number of site employees 8 Administration 1 Chemists Engineers and other technical professionals 1 Laboratory technicians 20 Operational/Production Personnel 1 Transport 1 Sales 2. Training

6 Does the Company have a formal operator-training program? If YES, are training records maintained? 3. Self inspection Does site perform self-inspections or audits? YES X NO If yes, with what frequency? See attached inspection forms; daily, monthly, weekly, yearly II. SITE DATA (continued) 4. Site Management How long has current site manager been at this site? 8/00 With the company? yes In the waste management business? yes E. Site Permits and Regulatory Factors 1. Part A Status (Attach copy of Part A ) 2. RCRA Part B Dates: Requested Submitted Judged Completed Permit Issued Provisions for expansions? 3. Agency inspections during last year and/or previous ones unsettled Last inspection date:4/7/05 4/8/05 #2 inspection date 4/14/05 Agency: Ohio EPA Hazardous Waste Division Status: In Compliance 4. Federal, State, County or local permits and/or licenses held by the The facility or transporter (obtain & attach current copies): Permit Issuing Agency Permit # s Date expires

7 Hazardous waste PUCO P Solid waste Water discharge Air emissions Other Surface Water Original Surface Water Addition SITE DATA (continued) 5. Has the site had formal violation notices or fines? YES X NO 6. How many violations in the last two (2) years? 1 7. List violations and dates of issue: 11/2006 Consent order covering off-spec. containers 8. Is the site currently under a compliance agreement or other Enforcement action from any environmental regulatory agency? YES X NO 9. If so summarize: Consent order implementation of approved Waste Analysis Plan and Facility Compliance Plan 10. In the operator s opinion, what is the sites relationship (excellent, Good, fair, etc.) with the surrounding community? Excellent 11. With the media? Excellent III. GENERAL FACILITY STANDARDS A. Facility Security 1. Is access to the facility controlled? YES X NO 2. Visitor Passes? YES X NO 3. Visitor Log Book? YES X NO

8 4. Is the facility fenced in completely? YES NO X 5. Is vehicular traffic controlled? YES NO X 6. Is area lighted? 7. Is facility guarded? YES NO X If yes, when is it guarded, i.e. 24 hrs. after working hrs. etc.? 8. Does the facility have an internal communications or alarm system capable of providing immediate emergency instructions to facility personnel?. A device at the scene of operations capable of summoning emergency assistance from police, fire department, etc.? B. Safety III. GENERAL FACILITY STANDARDS (continued) 1. Does the site have a safety plan covering all site operations? YES X NO 2. Is medical monitoring of employees conducted? YES NO X C. Emergency Response 1. Is the following fire protection equipment available on site? Pressurized hydrants/monitors Fire Truck (Water truck) Foam/Sprinkler System 2. How many miles to nearest outside emergency fire protection assistance? ½ Mile. 3. Does site have emergency response agreements with: Local Hospital Police Spill Response Contractor D. Laboratory Services 1. Which of the following pieces of equipment does the laboratory have on hand: ICP Mercury Analyzer

9 Mass Spectrometer Pensky Martins Flash Point Tester Bomb Calorimeter Ventilation Hood Other: Karl Fisher, Moisture meter Various Kits for Wet Chemistry YES NO X YES X NO 2. What are the laboratory operating hours? 7a.m. to 5p.m. Monday-Friday III. GENERAL FACILITY STANDARDS (continued) 3. What certifications does the laboratory have? None 4. Name of the principal chemist contact on site: Pat Oberth 5. Where does the lab waste go? _Solidification, Incineration, Fuel Blending E. Environmental Monitoring 1. Ground Water Monitoring a. Is ground water monitoring conducted on site? YES NO X Total number of monitoring wells Number of wells down gradient Number of wells up gradient Age range of wells b. Has monitoring indicated ground water contamination? YES NO X If yes, describe i. Frequency of monitoring? c. Parameters monitored 2. Surface water monitoring a. Does the site have a water discharge permit? YES NO X

10 If yes, list streams discharged by permit: b. Key parameters tested: c. Has the site had a chronic or major violation in reference to the Discharge permit? YES NO X If yes, describe d. Does the site conduct any off-site monitoring of nearby rivers, Streams or waterways? YES NO X If yes, is there any evidence of environmental damage caused by site activities? YES NO X If yes, please describe III. GENERAL FACILITY STANDARDS (continued) 3. Sewer Discharge Monitoring a. Does the site have a permit to discharge an offsite treatment facility? YES NO X b. Is the discharge monitored? YES NO If yes, what are the key parameters? d. How often are the samples collected? e. Is discharge monitored? YES NO If yes, is the composite sampled kept chilled YES NO f. Has the site had chronic problems in meeting sewer discharge standards? YES NO 4. Air Monitoring a. Does the site conduct air monitoring of specific sources? YES NO X If yes, list sources: b. Is there an automatic shutoff in the event that regulated levels are Exceeded? YES NO c. Does the site conduct ambient air monitoring? YES NO d. Has monitoring indicated any off-spec pollution problems? YES NO If yes, describe

11 F. Transportation 1. In house trucking capabilities Number of tractors: 3 Number of trailers: 9 (total) Vacuum trucks bulk: _ Dumps: 3 Vans: 6 Roll off Rails: 1 Roll off boxes: 5 Flatbeds: _ Other: 1 III. GENERAL FACILITY STANDARDS (continued) 2. Are trucks rinsed out on site? If yes, how is rinse water handled?: The waters are collected and placed into the solidification area. G. Waste Receipt and Shipping 1. Indicated the number of each type of receiving/shipping facility: Truck bulk loading/unloading racks: 1 Rail car bulk loading/unloading racks: 1 Truck drum docks: 3 Rail car drum docks: 2 Barge slips: _ Ship docks: _ Pipeline: _ 2. Is there a scale to weigh vehicles? YES NO X Do impermeable materials underlie loading/unloading areas? YES NO X If yes, what materials? H. *Waste acceptance * See permit waste acceptance 1. Outline the procedures or sequence of events to accept a new waste: Included in Audit Book

12 2. Does the site have a formal (written waste analysis plan? If yes, briefly summarize key components: Included in Audit Book 3. What parameters are used to fingerprint incoming waste? ph, Flashpoint, Odor, Color, Density, Halogens 4. For a bulk load, how many samples are taken? One Composite for Liquid, Grid pattern for Solids. Are these composite or analyzed separately? Composite for fingerprint 5. For a drum load, what percent drums are sampled? 100% 6. How is the waste tracked at the facility? Computer bar codes 7. Are unloading facilities curbed and/or have collection sumps? YES X NO Bulk trucks unloaded inside 8. Time required to accept a waste stream: 48hrs.

13 IV. FACILITY CAPABILITIES AND SCHEDULES (CHECK PAST AND PRESENT WASTE MANAGEMENT METHODS AT THIS SITE) Current Past A. Container Storage X B. Tanks X C. Waste Piles D. Surface Impoundments E. Solvent Recovery F. Carbon regeneration G. Resource Recovery H. Incineration I. Special waste physical/chemical Biological treatment (Waste fuel burning) J. Facility wastewater treatment X K. Landfarm M. Secure landfill N. Deep well injection O. Other facility capabilities: Engineered Fuel (Prep) X For each current disposal/treatment method checked, attach a corresponding schedule.

14 SCHEDULE A CONTAINERS 1. Estimate the numbers and type(s) of containers: Drums 3000 Hoppers Roll-off boxes 2 Other: Dewatering boxes 3 2. Describe container storage facilities (e.g. in. outdoors, covered or not, run-off control, etc. storage all indoors and on concrete, two sections used oil. 3. Are container(s) placed on an impermeable liner or concrete pad? YES X NO If yes, what? Concrete 4. Is there a container decant facility? YES NO X If yes, is there a fire suppression system? What type? A FFF 5. What happens to empty containers? Reused Reclaimed as scrap Steel, Plastic Land filled - Fiber Other X X 6. Are fiber/plastic drums incinerated? YES NO X If yes, what is the maximum size of drums incinerated?

15 SCHEDULE B TANKS 1. Are tanks used for storage? YES X NO If yes, tanks are used to store: New product Raw materials Wastes X Fuel 2. Are tanks used for treatment? YES NO X If yes, what type of treatment? 3. How many above ground tanks are located on site? 5 How many underground tanks (including in ground tanks are located at the site 0 4. For above ground tanks, describe the following: Number 5 Capacity (range) 1,500 1,300 Age range years Contents (waste/fuel/other) Water, Oil Composition Steel, Stainless Steel Construction (enclosed, open-top, prefabricated, constructed in place) Enclosed 5. Do above ground tanks have feed cut off system? YES X NO If yes, are they manual or automatic? Automatic high level, low level

16 6. Do above ground tanks have secondary containment? YES X NO If yes, give type 100% of all tanks concrete 7. For underground tanks, describe the following: Number 0 Capacity Age Contents (waste/fuel/other) Composition (fiberglass/steel/other) Construction (enclosed, open-top, prefabricated, constructed in place) SCHEDULE B TANKS (continued) 8. Do underground tanks have secondary protection or containment? N/A 9. For all tanks is a leak detection method used? YES NO X If yes, what method? 10. Do tanks have interior protection? YES NO X If yes, what type? 11. Are tanks integrity tested? YES NO X If yes, by what method? How frequently? 12. Have there been any leaks or spills associated with the site s tanks? No If yes, summarize the incident(s), response(s):

17 SCHEDULE J FACILITY WASTEWATER TREATMENT 1. Types of treatment: Gravity separation, water shipped to primary waste water treatment facility for further treatment. 2. Is treatment batch or continuous? Batch X Continuous 3. How is resulting sludge disposed? Tested and Solidified for Landfill 4. Is treated waste discharged to sewer system or surface water? YES NO X If yes, has a permit been obtained? YES NO X

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